(86 days)
The VivaTRAK™ system monitors in-bed activity and care delivery for patients susceptible to pressure ulcers and falls as well as those that require 24 hour monitoring of their general activity levels in medical, nursing and long-term care facilities including independent living, assisted living and rehabilitation facilities. The system providers information related to patient status and care delivered.
The VivaTRAK™ system is not intended to provide automated treatment decisions or used as a substitute for professional healthcare judgment. The VivaTRAK™ system is not a replacement or substitute for vital signs monitoring or alert equipment. All patient medical diagnosis and treatment are to be performed under direct supervision and oversight of an appropriate health care professional.
The VivaTRAK 110 system is used for monitoring in-bed patient activity and care delivery. The system monitors in-bed patient activity with the BedSense sensor, an under-the-mattress activity sensing pad, processing and wireless transmission of activity data with the ActivSense "M Bed Computer, and providing pager, email, phone and display notifications and care reports to the nursing staff, and then verifying using RFID readers that care was actually delivered with the VivaTRAKTM application. Care reports consisting of a notification, a RFID scan and bed activity are stored in a database and form the basis for reports used to improve quality of care and work flows at the facility.
The provided text is a 510(k) Pre-Market Notification Summary for the VivaTRAK™ system. This type of document is for regulatory clearance and focuses on demonstrating substantial equivalence to existing devices rather than a detailed performance study with acceptance criteria and statistical analysis as might be found in a clinical trial report for AI/ML devices.
Therefore, much of the requested information regarding acceptance criteria, sample sizes for test and training sets, expert qualifications, adjudication methods, MRMC studies, standalone performance, and ground truth establishment for a specific device performance evaluation is not present in this document. The summary focuses on regulatory comparisons and claims of meeting functional specifications rather than presenting detailed study results in the manner an AI/ML study would.
Here's a breakdown of what can be extracted and what information is missing:
Acceptance Criteria and Reported Device Performance
The document states: "Wireless MedCARE has verified and validated that the VivaTRAK™ system meets its functional, performance, safety, and efficacy specifications and requirements." However, it does not disclose what these specific functional, performance, safety, and efficacy specifications (i.e., acceptance criteria) are, nor does it provide a table of performance metrics to demonstrate meeting those criteria.
Table of Acceptance Criteria and Reported Device Performance (Information Not Provided):
| Metric/Acceptance Criteria | Reported Device Performance |
|---|---|
| (Specific acceptance criteria are not explicitly stated in the document) | (Specific performance metrics are not explicitly stated in the document) |
| Functional Specifications | Met |
| Performance Specifications | Met |
| Safety Specifications | Met |
| Efficacy Specifications | Met |
Study Information (Based on Available Text)
-
Sample size used for the test set and the data provenance:
- Sample Size: Not specified.
- Data Provenance: Not specified. The document states a "non-clinical performance summary" without detailing the type of data (e.g., patient data, simulated data) or its origin.
-
Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable/Not specified. The document does not describe a study involving expert-established ground truth for performance evaluation in the context of diagnostic accuracy. The device monitors in-bed activity and care delivery, which is likely validated through direct observation or automated logging, rather than expert interpretation of images or signals.
-
Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable/Not specified. This is typically relevant for studies where human disagreement needs to be resolved for ground truth or performance assessment, which is not described for this device.
-
If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- No. An MRMC study was not described or implied. The VivaTRAK™ system is described as providing information to nursing staff and verifying care delivery, not as an AI/ML diagnostic aid that human readers would interpret or use to improve performance.
-
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- The document implies that the system operates autonomously in monitoring activities and generating reports and notifications. It states, "The VivaTRAK™ system monitors in-bed patient activity... processing and wireless transmission of activity data... and providing pager, email, phone and display notifications and care reports to the nursing staff, and then verifying using RFID readers that care was actually delivered..." This suggests a standalone functional operation. However, no specific "standalone performance study" with detailed results (e.g., accuracy of activity detection, notification timeliness) is provided. Instead, it broadly states "meets its functional, performance, safety, and efficacy specifications."
-
The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Not explicitly stated. Given the device's function (monitoring in-bed activity and care delivery), the "ground truth" would likely be derived from direct observation of patient activity, direct logging of care delivery interactions (via RFID scans), or other objective measurements, rather than expert consensus on diagnostic images or pathology.
-
The sample size for the training set:
- Not applicable/Not specified. While the system "processes" data, the document does not suggest it uses machine learning models that require a distinct "training set" in the common sense of AI/ML development. It's a sensor-based monitoring system.
-
How the ground truth for the training set was established:
- Not applicable/Not specified, as no training set for an AI/ML model is described.
Summary of Device and Performance Claims from Document:
The VivaTRAK™ system is a "Monitor, Bed Patient" that:
- Monitors in-bed patient activity with an under-the-mattress sensor (BedSense).
- Processes and wirelessly transmits activity data with an "ActivSense™ Bed Computer."
- Provides pager, email, phone, and display notifications and care reports to nursing staff.
- Verifies care delivery using RFID readers and the VivaTRAK™ application.
- Stores care reports for quality improvement and workflow analysis.
The claims regarding performance are general: "Wireless MedCARE has verified and validated that the VivaTRAK™ system meets its functional, performance, safety, and efficacy specifications and requirements." The 510(k) clearance is primarily based on demonstrating substantial equivalence to predicate devices (AFrame Digital, Inc.'s AFrame MobileCare Monitor™, Stanley Security Solution's TAS Stilite, and Emfit Ltd's SafeBed) rather than presenting novel performance metrics from a detailed clinical/technical study with specific acceptance criteria.
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Pre Market Notification 510(k) Summary
1. Sponsor Information:
| Company Name & Address: | Wireless MedCARE, LLC.15 E. Salem Ave., Suite 201Roanoke, VA 24011 |
|---|---|
| ------------------------- | ---------------------------------------------------------------------------- |
JUL 1 5 2010
| Contact Person: | Kenneth D. Ferris |
|---|---|
| Contact Title: | COO |
| Contact Phone Number: | 540-520-8707 |
| Contact Fax Number: | 540-344-2966 |
April 9, 2010 Date of Summary:
2. Device Name and Classification:
Common and Usual Name: Monitor, Bed Patient
VivaTRAK™ Proprietary Name:
| Classification Name: | Bed-Patient Monitor |
|---|---|
| Classification Regulation: | 21CFR 880.2400 |
| Device Classification: | Class 1 |
| Product Code: | KMI |
Performance Standards:
No applicable performance standards have been issued under section 514 or under section 513 (b) of the Food, Drug and Cosmetic Act.
3. Predicate Device(s):
AFrame Digital, Inc., AFrame MobileCare Monitor (K090138), Stanley Security Solutions, Inc., TABS Elite (Class 1, 510(k) Exempt) Stanley Healthcare Solutions, Roll-Check (Class 1, 510(k) Exempt) Home Guardian, WellAWARE Systems (Class 1, 510(k) Exempt) Emfit Ltd., SafeBed (Class 1, 510(k) Exempt)
4. Description of Device:
The VivaTRAK 110 system is used for monitoring in-bed patient activity and care delivery. The system monitors in-bed patient activity with the BedSense sensor, an under-the-mattress activity sensing pad, processing and wireless transmission of activity data with the ActivSense "M Bed Computer, and providing pager, email, phone and display notifications and care reports to the nursing staff, and then verifying using RFID readers that care was actually delivered with the VivaTRAKTM application. Care reports consisting of a notification, a RFID scan and bed activity are stored in a database and form the basis for reports used to improve quality of care and work flows at the facility.
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5. Indications for Use:
The VivaTRAK™ system monitors in-bed activity and care delivery for patients susceptible to pressure ulcers and falls as well as those that require 24 hour monitoring of their general activity levels in medical, nursing and long-term care facilities including independent living, assisted living and rehabilitation facilities. The system providers information related to patient status and care delivered.
The VivaTRAK™ system is not intended to provide automated treatment decisions or used as a substitute for professional healthcare judgment. The VivaTRAK™ system is not a replacement or substitute for vital signs monitoring or alert equipment. All patient medical diagnosis and treatment are to be performed under direct supervision and oversight of an appropriate health care professional.
6. Comparison with Predicate Device (s):
The VivaTRAK™ system is substantially equivalent to the predicate devices (AFrame The Trial Inc.'s AFrame MobileCare Monitor Wonton No Tar Press (11 Marc, 1) Fulia
Digital, Inc.'s AFrame MobileCare Monitor™, Stanley Security Solution's TAS Stilite, and Emfit Ltd's SafeBed).
VivaTRAK is similar in characteristics, features, technological features, intended use, and indications for use, as the predicates. Any differences in the technology used when compared to the predicates have been satisfactorily addressed by conformance to FDA and Internationally recognized safety consensus standards as well as, to the company's design requirements. The VivaTRAK™ system is as safe and effective as the predicate devices.
7. Non-Clinical Performance Summary:
Wireless MedCARE has verified and validated that the VivaTRAK™ system meets its functional, performance, safety, and efficacy specifications and requirements.
8. Conclusions:
In summary, Wireless MedCARE is of the opinion that the VivaTRAK™ system is as safe and effective as similar devices currently on the market, and concludes that the VivaTRAK™ is substantially equivalent to the predicate devices and those 510(k) exempt products being marketed in U.S. interstate commerce.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features the department's name arranged in a circular fashion around a stylized emblem. The emblem consists of three abstract shapes that resemble human figures or stylized waves, stacked on top of each other.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Wireless MedCARE, LLC C/O Mr. Paul Sumner Arkin Consulting Group 1733 Canton Lane Marietta, Georgia 30062
JUL 1 6 2010
Re: K101109
Trade/Device Name: VivaTRAK™ Regulation Number: 21 CFR 880.2400 Regulation Name: Bed-Patient Monitor Regulatory Class: I Product Code: KMI Dated: July 7, 2010 Received: July 8, 2010
Dear Mr. Sumner:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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Page 2- Mr. Sumner
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801). please go to
http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely vours.
Nh for
Anthony D. Watson, B.S., M.S., M.B.A. Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
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Indications for Use Statement
510(k) Number (if known): N/A
Device Name: VivaTRAK™M
Indications for Use:
י
The VivaTRAK™ System monitors in-bed activity and care delivery for patients susceptible to pressure ulcers and falls as well as those that require 24 hour monitoring of their general activity levels in medical, nursing and long-term care facilities including independent living, assisted living and rehabilitation facilities. The system providers information related to patient status and care delivered.
The VivaTRAK™ System is not intended to provide automated treatment decisions or be used as a substitute for professional healthcare judgment. The VivaTRAK™ System is not a replacement or substitute for vital signs monitoring or alert equipment. All patient medical diagnosis and treatment are to be performed under direct supervision and oversight of an appropriate health care professional.
Prescription Use (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use X (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF
NEEDED)
(Division Sign-Off)
Division of Anesthesiology, General Hospital
Infection Control, Dental Devices
Concurrence of CDRH, Office of Device Evaluation (ODE),
510(k) Number: K101109
Wireless MedCARE VivaTRAK
§ 880.2400 Bed-patient monitor.
(a)
Identification. A bed-patient monitor is a battery-powered device placed under a mattress and used to indicate by an alarm or other signal when a patient attempts to leave the bed.(b)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 880.9.